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Main Conference: 20-21 March 2018Workshops 19 & 22 March 2018
Hilton Bankside,
London

Agenda Sessions

As the Australian Taxation Office continues to cement its position among the most influential tax administrations globally, Deputy Commissioner, Mark Konza takes to the TP Minds stage once again to deliver an insightful keynote speech focusing on on the work Australia has been doing in International taxation, with particular reference to the implementation of new laws such as the Multinational Anti-Avoidance Legislation (MAAL) and the Diverted Profits Tax (DPT).

Understanding the Tax Authorities’ Position on Key TP Challenges Arising from BEPS

Our annual Tax Authorities panel session has become a key highlight of our agenda. This is deliberately scheduled towards to close of the conference so that competent authorities can answer many of the questions raised by TP professionals during the many industry panel sessions held over the two main days of the event. Speakers will also be invited to comment on a number of timely topics including:

How have authorities set up structures to deal with information being provided under CbC reporting? What is the extent of resources being allocated to reviewing and dealing with the information arising? How is the work panning out in practice?

In relation to PE’s, how are authorities applying the new rules both in relation to determining whether there is a PE and attributing profits to that PE? What difficulties are being encountered? Are any situations being encountered where the new rules have been applied by other tax authorities in a way that creates concerns about potential double taxation?

How, if at all, have tax authorities changed their approach to transfer pricing following the revised OECD guidelines; for instance in relation “DEMPE” functions?

There is a general feeling within business that tax authorities will increase audits as a result of BEPS. Is that happening in practice and, if so, to what extent have they increased and with what results?

Business is concerned that there is or will be significant unilateral action to protect a particular country’s tax base which is not/will not be co-ordinated with what other countries are doing so that double taxation is likely to arise. Is that concern justified and how are authorities seeking to alleviate any potential difficulties?